Thank you for taking up much needed reforms to the Power Charge Indifference Adjustment (PCIA). Choice for an essential service, like electricity, should not create winners and losers.

We are concerned the proposed decision (PD) released on August 1 completely fails to prevent customer cost-shifts as required by law. The alternate decision (ADP) released August 13th by Commissioner Peterman is a big improvement but still allows for some cost-shifts to electricity customers who receive their power from investor-owned utilities.

Before voting on these proposals, we urge you to make modifications that will provide clarity and more effectively ensure all electricity customers, regardless of who provides their power, pay equitably for past investments in clean energy and system reliability.

Commissioner Peterman’s APD is a big improvement over the PD because it appropriately recognizes that current law requires that customers continue to pay for their equitable share of past investments in resources that serve systemwide reliability. This change was critical to ensure that customers who continue to buy power from investor-owned utilities are not forced to shoulder the costs incurred on behalf of other customers.

The ADP also seeks to address concerns with the proposed PCIA cap. However, the notion of a cap of any kind creates an artificial understanding of the cost of past investments. Shielding Community Choice Aggregators’ (CCA) customers from the reality of these costs causes bundled customers of investor owned utilities to pay for them or defers their recovery to a later time, resulting in increased costs for all electricity customers.

Because everyone benefits from clean energy and system reliability, the legislature twice took statutory steps to ensure that all electricity customers, regardless of who ultimately provides their power, would contribute equitably to cover the cost of these legacy investments.

More choices and energy providers are a good thing if they result in innovation and lower costs. But if lower costs for some customers are achieved through shifting of costs to other customers, that is not a legitimately competitive market. It also raises serious questions about how we continue to equitably fund future clean energy and environmental policies.

The message you send with your upcoming vote on this issue will either set the stage for the state to successfully navigate increased customer choice in the future or increase the risk of its failure. As our energy market continues to change and more customers buy power from CCAs and other alternative energy providers, it is critical that we get this right.

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EECC is a coalition of low-income, senior, business, labor, veteran and other diverse community groups that have come together, with support from the state’s three investor-owned electric utilities. The purpose of EECC is to support regulatory and policy changes to ensure bundled utility customers are not paying more than their share for clean energy and other power purchased for customers now being served by CCAs and other energy providers.